E-money and payment accounts
Issuing electronic money or operating payment accounts, where customer balances sit with your business rather than with a bank the customer chose.
- Published jurisdictions
- Singapore, Hong Kong
- Regulators involved
- 2 distinct authorities
Scope
What this permission family covers
Regulators assess the activity, not the product name. This is the activity that brings a business inside this family.
Issuing electronic money or operating payment accounts, where customer balances sit with your business rather than with a bank the customer chose.
Instruments in this family
Payment Services Act licence (e-money issuance and account issuance)
Singapore · Monetary Authority of Singapore
Stored Value Facility (SVF) licence
Hong Kong · Hong Kong Monetary Authority
Fit
Who needs this, and who does not
The negative list matters as much as the positive one. Businesses waste months applying for permissions they do not need.
Typically needed by
- Wallet and multi-currency account products
- Platforms that hold balances for users between transactions
- Card programme managers issuing on their own permission
Usually not needed by
- Businesses that route payments without ever holding customer balances
- Merchants using a licensed provider's account infrastructure under that provider's permission
Jurisdiction variant
The instrument depends on where you are authorised
E-money (EMI) is not a single permission. Choose a jurisdiction to see the instrument that applies there, the regulator that grants it, and what that regulator examines.
Stored Value Facility (SVF) licence
- Regulator
- Hong Kong Monetary Authority
- Scope of the authorisation
- Issuing and operating a stored value facility — a device- or account-based facility used to store value for making payments.
What this regulator examines
7Each area below is assessed against your actual business. Open one for the detail and the evidence normally expected.
Governance, fitness and propriety of controllersMandatory
Regulators assess who owns and runs the business: the board and senior management, the fitness and propriety of each controller, and the reporting lines that make the arrangement credible.
- Evidence: Organisational chart with reporting lines
- Evidence: Controller questionnaires and identity evidence
- Evidence: Curriculum vitae and regulatory history for senior appointments
Financial-crime frameworkMandatory
A documented framework covering customer due diligence, sanctions and PEP screening, transaction monitoring, suspicious-activity reporting and record keeping — proportionate to the business model and geography.
- Evidence: AML/CFT policy and procedures
- Evidence: Risk assessment covering customer, product, geography and channel
- Evidence: Named compliance officer and reporting arrangement
Business plan and financial projectionsMandatory
A regulator-grade business plan: the model, target customers, distribution, volumes, cost base and funding, with projections that reconcile to the capital and liquidity position.
- Evidence: Business plan
- Evidence: Financial projections
- Evidence: Funding and capital evidence
Client funds safeguarding arrangementsMandatory
Where the business holds funds belonging to customers, regulators require a documented safeguarding method, reconciliation controls and evidence of the arrangement with the safeguarding institution.
- Evidence: Safeguarding policy
- Evidence: Reconciliation procedure
- Evidence: Institution arrangement evidence
Operational resilience and technology controlsMandatory
Information security, change management, outsourcing oversight, business continuity and incident reporting arrangements appropriate to the permission being sought.
Local presence and substanceMandatory
A Hong Kong-incorporated company with local management accountability and operations the authority can supervise.
Float management and prudential arrangementsMandatory
The authority examines how the float is held, invested and reconciled, and the prudential arrangements that protect facility users.
After authorisation
Authorisation begins a supervisory relationship. These obligations continue for as long as the permission is held.
- Prudential and conduct reporting to the authority
- Float reconciliation and independent review
- Notification of changes to controllers and key personnel
Project model
How the programme runs
Three of these stages belong to the regulator. The platform records what the regulator has recorded and never anticipates a determination.
Readiness and gap analysis
YouStructured questions establish which requirement areas you already satisfy and which are open. The result is a gap list, not an assessment of whether a regulator will authorise you.
Scoping with a licensing specialist
Qualified providerA qualified licensing provider reviews the gap list, confirms the target permission and scopes the work into a proposal.
Application programme
Qualified providerPolicies, governance arrangements, controls documentation and the application pack are produced against the regulator's published requirements, tracked as milestones with document requirements.
Submission to the regulator
Qualified providerThe provider submits the application and records the submission evidence. From this point the state shown reflects the regulator's position.
Regulatory assessment
External authorityOutcome not controlled by ZKCAPThe regulator reviews the application and normally raises information requests. Each request appears as a first-class item with a response path, not as an email thread.
Determination
External authorityOutcome not controlled by ZKCAPThe regulator authorises, refuses, or authorises with conditions or limitations. The platform records whichever determination is issued, including refusal and its remediation path.
Ongoing supervision and renewals
External authorityOutcome not controlled by ZKCAPAuthorisation begins a supervisory relationship: reporting, notifications, attestations and periodic fees become tracked obligations.
Where this comes from
How this information is maintained
Boundary
Who is responsible, and who decides
A readiness assessment is not an application.